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In the notice of determination, respondent denied petitioner
relief from joint liability for her 1987 Federal income tax under
section 6015(f). The sole issue for decision is whether this
denial was an abuse of respondent’s discretion.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Kansas City, Missouri.
Petitioner married James Bradley Barber (Mr. Barber) in
January 1983. Mr. Barber testified at trial but did not
intervene in the proceeding, nor did he object to petitioner’s
claim for relief. Petitioner and Mr. Barber had one son, born in
1989. They divorced in December 1998.
During the year at issue, petitioner was employed by
American City Business Journals (ACBJ) in the human resources
department. In 1988, petitioner’s employment with ACBJ was
terminated when the company relocated its offices to North
Carolina. Thereafter, she was a homemaker and primary caretaker
of her son but occasionally had jobs outside the home. In 1987
and subsequent years, Mr. Barber was self-employed as a painter
and paperhanger.
Petitioner and Mr. Barber experienced financial difficulties
during their marriage, particularly after their son was born, and
petitioner was no longer employed. Their money was often spent,
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